The pandemic has altered practice patterns and usage of behavioral health services, making explicit the consequences of paying too little for essential behavioral health care, or providing no mechanism for expansion and redistribution of the most valuable services to those who need them. Federal and state legislation, regulatory adjustments, executive orders and payor guidance seek to address the current pandemic crisis as well as decades of disparities in behavioral health access, acceptance, training, and payments.

The existing study identifies the key elements of predominant payment models, capitation and fee-for-service, and focuses on the role of Medicaid as the primary source of funding and payment for behavioral health relative to commercial and Medicare payment. It documents disparities in behavioral healthcare, examine untapped mechanisms for improving access to behavioral healthcare providers, and shed light on the role of payment models in future demand and supply of quality services.

The principle aim of this study is to determine how characteristics of payment models result in variations in supply of behavioral health providers over the course of the 2020 COVID-19 pandemic in the US. This is an observational study of payment model design features in relevant legislation, regulations and executive orders affecting Medicaid and commercial plans. It will analyze variation in fees and payment for behavioral health services delivered by the current and developing behavioral health workforce under 2020 federal and state legislation, agency regulations, and CMS and Department of Labor policy and guidance concurrent with and following the national state of emergency declared due to the COVID-19 pandemic.



Results demonstrate that the majority of CCBHCs do not have PPS or QBP arrangements in place with MCOs or commercial payors; only 1 CCBHC had implemented any PPS or QBP. However, another 3 were negotiating these arrangements, suggesting that more CCBHCs are working with MCOs and commercial payers to establish APMs.

Three of the 4 CCBHCs implementing or negotiating PPS or QBP arrangements with commercial payers participated in the Medicaid Demonstration program. This early finding suggests that participation in the Medicaid Demonstration is correlated with interest in establishing a PPS or QBP with other payor types. This may be due to the fact that these sites already have a mandated PPS required by the Medicaid Demonstration, providing experience costing and managing a PPS rate, which may make them more equipped to and interested in negotiating a PPS with other payors. However, this may also reflect other differences between CCBHCs participating and not participating in the Medicaid Demonstration. For instance, the organizational characteristics that made them competitive for the Medicaid Demonstration program may be the same as those that make them ready and able to negotiate and implement PPS and QBP.

As CCBHCs become more established, it is expected that the number of CCBHCs negotiating and implementing these relationships is likely to increase.